Two Step Confession. The Second Circuit has ruled that a inculpatory statement made after the criminal defendant was Mirandized was admissible even thought the authorities had obtained a earlier inculpatory defendant from the defendant before he had been Mirandized. The Court held that a deliberate two-step strategy had not been used by the government; such a strategy would have warranted suppression under Supreme Court precedent.

The decision in United States v. Carter can be found here.